Anti-Corruption Policy and Guidelines

The Company determined to operate the business with honesty, transparency and fairness in accordance with the principle of good governance. And in order to prevent and suppress corruption, the company has devised the “anti-corruption policy and practices” for staff members of the company and subsidiaries to understand and use as clear instructions in the operations to ensure that the Company has the appropriate and sufficient internal control system to guard against corruption, clear execution protocols, preventive and responsive measures have been identified to suit the business, to ensure that directors, executives and staff members comply with the Anti-Corruption Policy, in accordance with the business operation goals that are totally free of corruption. Corruption is considered unlawful, and the Company refuses to tolerate it (Zero Tolerance).

Anti-Corruption Policy

“The Company’s directors, executives and staff members are prohibited from supporting corruption or accepting corruption of all sorts, for one’s own direct or indirect benefits, or for one’s family members, friends, acquaintances, regardless whether one is the receiver, giver or offer of the bribes; monetary or non-monetary, to individuals, government officers, government bodies or private sector organizations that deal businesses with the Company. This includes businesses of subsidiaries, associates or other companies with the authority, and the anti-corruption protocols must be strictly observed. The responsible party structure and risk management system should be established, as well as the internal control and internal audit systems to prevent and suppress dishonest acts or organizational corruption, as well as to review the practices and operational regulations to align with changes in the business, regulations and the laws.”

Anti-Corruption Guidelines

1. Directors, executives and all levels of staff members must comply with the Anti-Corruption Policy, Business Code of Conduct, relevant policies and practices. They must also comply with the laws related to anti-corruption, not getting involved in conduct that implies dishonesty and corruption either directly or indirectly, for one’s own interests and/or that of others.
2. All staff members must not neglect or ignore when detecting potential acts of dishonesty or corruption related to the Company and subsidiaries. They must notify the supervisor or submit the case via the designated whistle blowing channels. They must cooperate with fact-finding procedures. If there are any questions or doubts, the immediate supervisor or designated personnel can be consulted with.
3. The Company will ensure fairness and protection for staff members who deny corruption or notify corruption issues related to the Company. The Company has clearly prescribed the protective measures for whistle blowers, and it will not blame or proceed with any unfair execution to demote, punish or cause negative impact on staff members denying corruption, even if such act may cause the Company to lose business opportunities.
4. Directors, executives, and staff members of all levels known to commit acts of corruption are considered breaching the Company’s Code of Conduct and will be subject to disciplinary considerations specified by the Company, with no limitations to legal proceedings if such acts are illegal.
5. The anti-corruption measurement is a part of the business operation and it is the duty and responsibility of the Company’s Board of Directors, The Management, supervisors, and employees at all levels including suppliers or sub-contractors to express their opinions regarding the practice on the implementation of the anti-corruption actions to ensure achievement of compliance with the policy set.
6. Develop the anti-corruption system to align with relevant laws, putting in place the appropriate and sufficient internal control system, as well as conducting risk assessments for related activities or ones that are prone to corruption risks. Clear protocols and execution measures are to be prescribed for staff members and related parties.
7. Encourage the anti-corruption culture and foster an awareness of honest and transparent operations. Organize communication and training courses to build knowledge and understanding for staff members and encourage anti-corruption among suppliers, customers, and stakeholders, as well as information disclosure with the public.

Whistleblowing and Complaint Filing Mechanisms

The Company has arranged for credible and independent channels for filing complaints and whistleblowing in case of legal or ethical misconduct, violation of the anti-corruption policy or behaviors that may suggest dishonesty and inappropriate conduct of organizational members; staff members, executives and stakeholders. Everybody, either the Company’s staff members or outsiders, is allowed opportunities to provide clues, thus they are required to notify of the possibility of corruption via available channels. Punishment shall be exercised upon the person who is aware of the information or incident that may involve corruption but fails to notify the responsible parties. The Company has the measures on protecting whistleblowers, with mechanisms to protect providers of information, and emphasizes on keeping the complaints confidential, in order to build confidence for the complainants. Nevertheless, punishment will be exercised upon those who provide untrue information.